Public Comment

In this comment, we show that transparency, best available science, and
meaningful public participation are not the goal of this rule. Rather, the goal is to
reduce the range of evidence that is used in regulatory decision-making and to
make it harder to use scientific evidence that shows harm caused by chemical
exposures. This rule will prevent deeper understanding by scientists, regulators,
and the public of the risks of chemical exposures and, ultimately, will delay action
to protect environmental and public health.

EDGI’s comment points to the substantial amount of information relevant to the Clean Power Plan and its proposed repeal that was removed from the EPA website over the course of the previous year. For the public and regulated bodies to understand the feasibility of implementing the CPP, they must have continued access to comprehensive information about the purpose and scope of the Plan, the basis for calculating its costs and benefits, technological considerations, and proposed implementation strategies. March 12, 2020 Comment Title: “Public Comments on the Proposed Changes to the National Environmental Policy Act. ” Submitted by the Environmental History Action Collaborative (EHAC) and members of the Website Monitoring Team, EDGI’s comments finds that the majority of the proposed rule changes are at cross-purposes with the original intent of NEPA, and urges rejection of proposals that: (a) minimize the substantive elements of NEPA; (b) arbitrarily limit the scope and length of EIS review; (c) reduce public participation in the NEPA process; (d) expand categorical exclusions; (e) limit the consideration of indirect and cumulative effects, and (f) restrict judicial review.

According to our research, the RMP amendments will improve the safety of chemical
processing, improve information access for first responders, and protect local communities. The
amendments also implement good data governance practices to ensure that Local Emergency
Planning Committees (LEPCs) , emergency response officials, and members of the public can5
better access risk assessments and emergency-response information from facilities. By
improving accident prevention program requirements and enhancing emergency preparedness,
the RMP amendments protect communities and first responders.